Poland: Proposals to revise transfer pricing documentation rules

Poland: Revise transfer pricing documentation rules

Draft amendments (published at the end of April 2015) would introduce significant changes to the rules governing the relationship between related parties, especially in terms of documentation of transactions between related parties.


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If finalized, this would be the first extensive reform of the transfer pricing documentation rules since being introduced in Poland’s law in 2001. The changes are intended to comply with the latest recommendations from the European Union and of the OECD under its base erosion and profit shifting (BEPS) project.

The measures include provisions that would:

  • Change the definition of related parties, and provide a new capital relations threshold
  • Provide new rules on tax documentation and on the scope of documentation
  • Revise the deadlines required for preparing and submitting the documentation


Read a May 2015 report [PDF 303 KB] prepared by the KPMG member firm in Poland: Draft law on transfer pricing regulations

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